Daewoo Electronics America Inc. v. Opta Corp.

This case presents a complex issue of interjurisdictional preclusion, but it can be solved easily if one adheres to first principles. The preclusive effect of a prior judgment in a federal diversity action is governed by the law of the state in which the rendering court sits. Semtek Int’l Inc. v. Lockheed Martin Corp., 531 U.S. 497, 506-08, 121 S.Ct. 1021, 149 L.Ed.2d 32 (2001). Here, Daewoo received a prior judgment in a federal diversity action filed in the District of New Jersey. The preclusive effect of that prior judgment is therefore governed by New Jersey state law.

There are two…